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Privacy Policy

Last updated: 31 March 2026

Contents

  1. Introduction
  2. Data Controller
  3. What Personal Data We Collect
  4. How We Collect Data
  5. Legal Basis for Processing
  6. How We Use Your Data
  7. Data Sharing
  8. International Transfers
  9. Data Retention
  10. Your Rights Under UK GDPR
  11. Cookies
  12. Security
  13. Children's Privacy
  14. Changes to This Policy
  15. Contact Us

1. Introduction

Pamoja Group is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process personal data in relation to our website, investor relations activities, and business operations.

We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, which set out the legal framework for data protection in the United Kingdom.

2. Data Controller

Pamoja Group is the Data Controller for personal data processed through our website and business activities.

Correspondence: please reach the Data Protection Officer via our contact form.

Data Protection Officer: reachable via our contact form.

3. What Personal Data We Collect

  • Contact Information: Name, email address, phone number, company name
  • Enquiry Details: Information you provide when submitting contact forms or making enquiries
  • Technical Data: IP address, browser type, operating system, pages visited
  • Cookie Data: Information collected through cookies and similar technologies
  • Investor Information: For investor relations purposes, financial and professional information

4. How We Collect Data

  • Directly from You: When you complete contact forms, email us, or interact with our website
  • Automatically: Through cookies, analytics tools, and server logs when you visit our website
  • From Third Parties: From service providers, partners, and publicly available sources
  • Consent: Where you have given explicit consent (e.g., marketing communications)
  • Legitimate Interests: Where we have legitimate business interests not overridden by your rights
  • Contractual Necessity: Where processing is necessary to fulfil a contract with you
  • Legal Obligation: Where we are required by law to process your data

6. How We Use Your Data

  • Responding to your enquiries and communications
  • Investor relations and engagement activities
  • Sending marketing communications (where you have opted in)
  • Improving our website functionality and user experience
  • Conducting analytics and understanding user behaviour
  • Ensuring legal compliance and fraud prevention

7. Data Sharing

We may share personal data with service providers, professional advisors, law enforcement (where required by law), and other Pamoja Group entities. We do not sell your personal data to third parties.

8. International Transfers

Some data may be transferred to Kenya, Uganda, and the UAE where Pamoja Group operates. Where we transfer data internationally, we implement Standard Contractual Clauses or other appropriate safeguards.

9. Data Retention

  • Enquiry Information: 3 years from last contact
  • Website Analytics: 13 months from collection
  • Investor Information: Duration of relationship plus 6 years
  • Legal and Compliance Records: 6-7 years as required by UK law

10. Your Rights Under UK GDPR

  • Right of Access, request a copy of data we hold about you
  • Right to Rectification, ask us to correct inaccurate data
  • Right to Erasure, request deletion under certain circumstances
  • Right to Restrict Processing, limit how we use your data
  • Right to Data Portability, request your data in a portable format
  • Right to Object, object to processing for marketing or legitimate interests
  • Right to Lodge a Complaint, complain to the ICO

To exercise any right, please reach out via our contact form.

11. Cookies

Our website uses cookies. For detailed information please refer to our Cookie Policy.

12. Security

We implement appropriate technical and organisational measures to protect personal data, including encryption in transit and at rest, access controls, and regular security assessments. No internet transmission is completely secure.

13. Children's Privacy

Our website is not directed to children under 16. We do not knowingly collect personal data from children under 16.

14. Changes to This Policy

We may update this policy from time to time. Changes will be indicated by the "Last updated" date above. Continued use of our website constitutes acceptance of updates.

15. Contact Us

Data Protection Officer: reachable via our contact form.

ICO: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, ico.org.uk